WalkMe Ltd. and its affiliates (“WalkMe“, “we” or “us“) is committed to protecting the privacy of the users of its website at the address www.WalkMe.com (the “Site“) and its online products, including the WalkMe System™, WalkMe Mobile™ and Visions™ (each a “Service” and collectively the “Services“).

A User may be either an entity which executed an agreement with WalkMe or with WalkMe’s resellers or distributors who provide WalkMe’s Services (“Customer“) or Customer’s users of the Services (“End User(s)“) or visitors of the Site (collectively “Users” or “you“).

This Policy explains the types of information we may collect from you or that you may provide when you visit the Site or use the Services and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please note: this Privacy Policy details WalkMe’s practices for the Site and Services it offers separately. In order to have the full picture of our privacy practices, you need to read the relevant Section about the Services you are using together with the General Section.

1. WalkMe System™

For information about the privacy and data retention practices in connection with the WalkMe System™ please click here.

2. WalkMe Website

For information about the privacy and data retention practices in connection with the Site please click here.

3. WalkMe Mobile™

For information about the privacy and data retention practices in connection with the WalkMe Mobile™ please click here.

4. Visions™

For information about the privacy and data retention practices in connection with the Visions™ please click here.

5. General (this Section applies for all Services)

Please refer to the specific Section(s) about the Site or Services you use or plan to use for a complete review of the relevant practices.

a. Consent and Principals of Processing Data

WalkMe processes data fairly, lawfully, in a transparent manner and in accordance with individuals’ rights (as applicable). The use of information collected through our Services shall be limited to the purpose of providing the service for which our Client has engaged WalkMe.

WalkMe may process data of an End User on behalf of the Controller when the Controller obtains consent from an End User or when there is another basis for doing so under applicable law. For purposes of this Privacy Policy, a Controller may mean a Customer or anyone acting a Customer’s behalf. (the “Controller”), Customers who cause WalkMe to process Personal Information of an End User are obligated to hold all appropriate consents (if applicable) and may only utilize the Services pursuant to applicable law. If you are an End User of the Services, please contact the Controller for additional detail. We may transfer Personal Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the service agreements with our Customers (the Controller). Furthermore, WalkMe supports End Users’ rights to retrieve any information retained on our servers which relates to such End User. WalkMe acknowledges that you have the right to access your Personal Information. We have processes in place to accommodate an End User’s rights to delete data, amend erroneous data, access data and receive Personal Data or Sensitive Data in a machine readable commonly used format, all subject to reasonable technical restrains and abilities. For more information, please see the Section “Modification or Deletion of Data” under the applicable Site or Service Section.

Personal Information or Personal Data is information by which an individual may be personally identified, including name, address, e-mail address, telephone number or any other information that is defined as Personal Information, Personal Data, or Personally Identifiable Information under an applicable law (hereinafter referred to as “Personal Information”)

Users are not obligated to provide us with any information by law. However, we require certain information in order to operate properly. Under some jurisdictions (such as under certain E.U. regulations), a User has a right to withdraw its consent at any time. In such a case, the withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

Please note that consent for the gathering and processing of data for one Service does not automatically mean that a User consents to the processing of data in connection with other Services. Controller should always make sure that the User’s consent is relevant, clear, valid, and to the extent reasonably possible, not “bundled” with any other written agreement (especially if required under applicable laws), unambiguous and if required under applicable law, affirmative and active (meaning not by virtue of any inaction).

WalkMe aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. WalkMe only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy.

b. Minors

We do not knowingly collect or solicit information or data from children under the age of 13 or knowingly allow children under the age of 13 to register for the WalkMe Service. If you are under 13, do not register or attempt to register for any of the WalkMe Service or send any information about yourself to us. If we learn that we have collected or have been sent Personal Information or Personal Data from a child under the age of 13, we reserve the right to delete that Personal Information or Personal Data as soon as reasonably practicable. If you believe that we might have collected or been sent information from a child under the age of 13, please contact our legal@walkme.com as soon as possible.

c. Information Security

We take great care in implementing, enforcing and maintaining the security of our Services, Site and Users’ information. WalkMe implements, enforces and maintains security policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Information or Personal Data and to monitor compliance of such policies on an ongoing basis. The information is hosted on the Amazon Cloud in the United States which provides advanced security features and is compliant with the ISO 27001 standard. All information is stored with logical separation from information of other Customers. However, we do not guarantee that unauthorized access will never occur.

We use a combination of processes, technology and physical security controls to help protect Personal Information and Personal Data from unauthorized access, use, or disclosure. When Personal Information or Personal Data is transferred over the Internet, we encrypt it using Transfer Layer Security (TLS) encryption technology or similar technology. Each server is protected by a firewall, exposing it only to the minimum ports necessary. However, no security controls are 100% effective, and we cannot completely ensure or warrant the security of your Personal Information and Personal Data.

Unless otherwise agreed with the Customer and subject to applicable law, WalkMe shall act in accordance with its policies to promptly notify Customer in the event that any Personal Information or Personal Data processed by WalkMe on behalf of a Customer is lost, stolen, or where there has been any unauthorized access to it.

WalkMe uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the WalkMe Service. Where practical, we seek to obtain confidentiality agreements that are consistent with this Privacy Policy and that limit others’ use or disclosure of your Personal Information and Personal Information.

d. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Site and Service and any information collected in connection therewith, however, WalkMe may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will always be posted at http://www.walkme.com/privacy-policy. We will endeavor to provide notice of material changes to this policy on the homepage of the Site and/or via an e-mail. Such material changes will take effect seven (7) days after such notice was provided on our Site or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site and/or Services will constitute your acceptance of, and agreement to be bound by, the changes to the Privacy Policy.

e. EU-US Privacy Shield and Swiss-U.S. Privacy Shield

WalkMe, Inc. and its parent company WalkMe, Ltd. participate in and have certified their compliance with the E.U.-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. WalkMe, Inc. is committed to subjecting all personal data received from European Union (E.U.) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.

WalkMe Inc. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. WalkMe, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the E.U. and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, WalkMe is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, WalkMe may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

You can direct any questions or complaints about the use or disclosure of your E.U. Personal Data to legal@walkme.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your E.U. Personal Data within 45 days of receiving your complaint.

f. Questions, Contact Information and Complaints

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email or otherwise contact us at the following address and we will make an effort to reply within a reasonable timeframe.

E.U. citizens have the right to lodge a complaint with a supervisory authority (Data Protection Authority in your jurisdiction) in case of a breach of any E.U. data protection and privacy regulations. If the supervisory authority fails to deal with a complaint or inform you within the time frame set under applicable law, you have the right to an effective judicial remedy.